Fact Sheet
Health Information and Data Sharing
The HIPAA Minimum Necessary Rule in the Age of Data Modernization
November 13, 2025
Overview
Twenty-five years after the finalization of the Privacy Rule, the public health landscape—particularly with respect to information technology and the way information is submitted to public health—has changed considerably. This fact sheet takes a fresh look at an old rule and explores how a requirement that predates Y2K applies to public health reporting in the era of data modernization.